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CALIrOSINt• Water Boards ..,100, "lb MA MVIR TTEW r0.001110UEZ V OMPAINTAL MIOTIC1.0.1 E01111010 G. &norm JA. Central Valley Regional Water Quality Control Board 13 September 2018 Min Le McBillin Real Estate Investment 3293 Napa Drive San Jose, CA 95148 McBILLIN REAL ESTATE INVESTMENT, 2154 S. EL DORADO STREET, STOCKTON, SAN JOAQUIN COUNTY, CASE# 391184 Central Valley Regional Water Quality Control Board (Central Valley Water Board) staff reviewed the Revision to Pilot Test Work Plan (Revised Work Plan) dated 24 August 2018, submitted on your behalf by Advanced GeoEnvironmental Inc. (AGE) for the McBillin Real Estate Investment unauthorized petroleum release at 2154 S. El Dorado Street in Stockton (Site). In the Revised Work Plan, based on the equipment to be used and the estimated injection rate of 3-6 cubic feet per minute, AGE estimates that a total of between 1,440 and 2,880 cubic feet of air will be injected over the course of the 8-hour test. Additionally, AGE proposes a Contingency Plan in the event that concentrations of selected remedial parameters increase more than 20% over the course of the pilot test. The proposed contingency Plan is to consist of bulk pumping of approximately 5,000 gallons from wells IAS-1 and/or MW-6. In the event that post-pilot test concentrations are greater than 20% above the baseline concentrations, prior to implementation of the Contingency Plan, a confirmation sample should be collected from both wells approximately one month following the post-pilot test sampling. Should the confirmation sample concentrations remain more than 20% above the baseline concentrations, then the contingency plan should be implemented. Collectively, in the June 2018 Work Plan and the August 2018 Revised Work Plan, AGE proposed completing the pilot test as presented in Table 1, 2, and 3 below. Table 1 - Remedi Well Location Function Total Depth (ft bgs) Screen Interval (ft bgs) Target Zone Soil Sampling Analysis Depth (ft bgs) VW-1 Between former USTs 3 & 4 Soil Vapor Extraction 25 10-25 Vadose 5ft intervals from 5ft to Total Depth TPHg, TPHd, BTEX, MTBE, TAME, DIPE, ETBE, TBA, 1,2-DCA, EDB, naphthalene VW-2 Between former USTs 1 & 2 VW-3 Near boring B-3 IAS-1 Between former USTs 2 & 3 In-Situ Air- Sparge 35 30-35 Shallow Ground- water IAS-2 Near boring B-3 — g-I-'ht0t0I petroleum hydrocarbons as gasoline; TPHd=TPH as diesel; BTEX= benzene, toluene, ethylbenzene, xylenes; MTBE=methyl tert butyl ether; TAME=tert amyl methyl ether; DIPE=di-isopropyl ether; ETBE=ethyl tert butyl ether; TBA=tert butyl alcohol; 1,2-DCA=1,2-dichloroethane; EDB=ethylene dibromide; ft=feet; bgs=below ground surface; UST=underground storage tank KARL E. LoNoLsy ScD, P.E., CHAIR I PATRICK PULUPA, ESO., EXECUTIVE OFFICER 11020 Sun Center Dnve e200, Rancho Cordova, CA 95670 I www.waterboards.ca.govtcentralvalley Ca REC YCL ED TAPER